PAIND – WEBSITE PRIVACY NOTICE

This privacy policy gives you information about how Oso Pain Management Ltd collects and uses your personal data through your use of this website, including any data you may provide when you sign up to us or download our app. If you do use our app, then this is subject to a separate privacy policy which can be found here: PAIND Mobile App Privacy Policy

This policy is provided in a layered format so you can click through to the specific areas set out below.

Important information and who we are

Oso Pain Management Ltd is the controller and is responsible for your personal data (collectively referred to as "Paind", "we", "us" or "our" in this policy).

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Oso Pain Management Ltd

Name or title of data privacy manager: Charles Balcombe

Email address: hello@paind.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 05/06/2024. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

This website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
  • Contact Data: email address.
  • Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the wireless network interface), mobile operating system, the type of browser you use, time zone setting.

We do not collect any aggregated data through our website.

How is your personal data collected?

We will collect and process the following data about you through our website:

  • Information you give us. This is information you consent to giving us about you by signing up to Paind on the website, or by corresponding with us (for example, by email or chat).

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see [INSERT LINK TO COOKIE POLICY].

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.
  • Where we need to perform a contract we are about to enter or have entered with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

Data retention

Details of retention periods for different aspects of your personal data are available by contacting us.

By law we have to keep basic information about our users (for six years after they cease being users for tax purposes).

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use website or our app for a period of 12 months then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at hello@paind.com

Glossary

Lawful Basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

External Third Parties

  • Service providers acting as processors based in the UK and Europe who provide various administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide banking, legal, insurance and accounting services.
  • HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

Your Legal Rights

You have the right to:

  • Request access to your personal data: This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you: This enables you to have any incomplete or inaccurate data we hold about you corrected.
  • Request erasure of your personal data: This enables you to ask us to delete or remove personal data under specific circumstances.
  • Object to processing of your personal data: This allows you to object to our processing of your personal data where we are relying on a legitimate interest or processing it for direct marketing purposes.
  • Request restriction of processing of your personal data: This enables you to ask us to suspend the processing of your personal data under certain conditions.
  • Request the transfer of your personal data: This allows you to receive your personal data in a structured, commonly used, machine-readable format.
  • Withdraw consent: You can withdraw your consent at any time where we rely on it as a lawful basis for processing your personal data.

Description of Categories of Personal Data

  • Identity Data: First name, last name, display name, date of birth, gender.
  • Contact Data: Billing address, delivery address, email address, telephone numbers.
  • Financial Data: Bank account and payment card details.
  • Health Data: Details about your general mental and physical health.
  • Transaction Data: Details about payments to and from you, in-Web App purchases.
  • Device Data: Type of mobile device, unique device identifier, mobile network information, mobile operating system, type of mobile browser, time zone setting.
  • Content Data: Information stored on your device, including posts, photos, videos, check-ins.
  • Profile Data: Display name, Web App purchase history, bio, preferences, feedback, survey responses.
  • Usage Data: Details of your visits to the Web App and the App Site, traffic data, communication data, resources accessed.
  • Marketing and Communications Data: Preferences in receiving marketing, communication preferences.
  • Location Data: Static location provided through the app.